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Go to I.R.C. § 6663 (not yet in the library — opens the official source)
59 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. Circular 230 § 10.51(a)(9) — Incompetence and disreputable conduct.
    Joint BoardRegulationsDec 30, 2016related by meaning
    (a)(9) (9) Directly or indirectly attempting to influence, or offering or agreeing to attempt to influence, the official action of any officer or employee of the Internal Revenue Service by the use of threats, false accusations, duress or coercion, by the offer of any special inducement or promise of an advantage, or b…
  2. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
    IRCCourt RulingsSep 10, 2008
    …e in willful tax evasion and with determinations of willful civil tax fraud penalties under section 6663. See, e.g., Spies v. United States, 317 U.S. 492, 499 (1943). . Indeed, in this case petitioner filed its corporate Federal income tax returns for 1994 and 1995 without claiming deductions for redemption dividends. …
  3. T.C. Summary Opinion 2005-108 — Magellean Askew, Jr. v. Commissioner
    IRCCourt RulingsAug 1, 2005related by meaning
    his annuity policies. As stated earlier, section 72(e)(5) applies to the surrender of an annuity contract. See sec. 72(e)(5)(E). Absent exceptions not applicable in the instant case, the law is well settled that a distribution upon the complete surrender of an annuity contract is includable in gross income to the exten…
  4. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …x for failure to pay estimated income tax), section 6662(a) (accuracy-related penalty), and section 6663(a) (fraud penalty). Second, structurally, section 72(t) is part of chapter 1 of subtitle A of the Internal Revenue Code. Subtitle A is denominated "Income Taxes" and chapter 1 is denominated "Normal Taxes and Surtax…
  5. T.C. Summary Opinion 2013-96 — Samuel & Lilian Brach v. Commissioner
    IRCCourt RulingsDec 2, 2013related by meaning
    ion 6662(a) and (b)(2) imposes an accuracy-related penalty equal to 20% of the amount of any underpayment of tax that is attributable to a substantial understatement of income tax. By definition, an understatement is the excess of the tax required to be shown on the tax return over the tax actually shown on the return.…
  6. T.C. Memo. 1998-52 — Robert E. Dunham v. Commissioner
    IRCCourt RulingsFeb 9, 1998
    …lent, we consider the same elements that are considered in imposing the fraud penalty under section 6663. Clayton v. Commissioner , 102 T.C. 632, 653 (1994). Fraud is an intentional wrongdoing designed to evade tax known or believed to be owing. Edelson v. Commissioner , 829 F.2d 828, 833 (9th Cir. 1987), affg. T.C. Me…
  7. T.C. Summary Opinion 2002-33 — Wallace F. & Mi-Ja H. Smith v. Commissioner
    IRCCourt RulingsApr 3, 2002related by meaning
    ules or regulations. 6 Section 6662(a) provides that, if it is applicable - 14 - 6 (...continued) underpayment of tax may not exceed 20 percent of the underpayment, notwithstanding that the portion is attributable to more than one of the types of misconduct described in sec. 6662(a). Sec. 1.6662-2(c), Income Tax Regs. …
  8. T.C. Summary Opinion 2005-127 — Timothy J. Glenn v. Commissioner
    IRCCourt RulingsAug 16, 2005related by meaning
    ted penalty pursuant to section 6662(a) with respect to the underpayment attributable to the unreported 10-percent additional tax under section 72(t). Section 6662(a) imposes a 20-percent penalty on the portion of any underpayment attributable to any of various factors, one of which is negligence or disregard of rules …
  9. T.C. Memo. 2012-13 — John K. Goyak & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 11, 2012related by meaning
    al authority unde section 6664. See Rule 142(a);.Higbee v. Commissioner, supra at 446-447. Respondent has met the burden of production by showing that petitioners improperly deducted or failed to rëport $1.4 million contributed to the Millennium Plan and used the funds to purchase assets for the primary benefit of Mr. …
  10. T.C. Memo. 2025-23 — Charlie Campana v. Commissioner
    IRCCourt RulingsMar 19, 2025related by meaning
    applies, w e sustain respondent’s determination that petitioner owes the additional tax under section 72(t)(1) for 2021 . IV. Section 6662(a) Penalty Section 6662(a) and (b)(2) impose s an accuracy-related penalty equal to 20% of the portion of an underpayment of tax required to be shown on a return that is attributab…
  11. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
    IRCRevenue ProceduresDec 30, 2024related by meaning
    —Shared Responsibility for Employers Regarding Health Coverage.—Whether an employer is required to make an assessable payment under § 4980H(a) or (b). (136) Section 6050P.—Returns Relating to the Cancellation of Indebtedness by Certain Entities.—Requests for a ruling that the creditor is not required to report a discha…
  12. 29 C.F.R. § 4000.21 — What are these rules for determining the filing or issuance date about?
    PBGCRegulationsJan 1, 2017
    …r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…
  13. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    as either unable to pay the tax or would suffer an undue hardship if he or she paid on the due date. See sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Respondent concedes that he has not met his burden of production on this issue because he failed to introduce into evidence the substitute for return that he purportedly…
  14. 29 C.F.R. § 4000.26(b) — What if I use a commercial delivery service?
    PBGCRegulationsJan 1, 2017
    …t use a “designated delivery service” under section 7502(f) of the Internal Revenue Code (Title 26, USC). Our Web site, http://www.pbgc.gov, lists those designated delivery services. You should make sure that both the provider and the particular type of delivery (such as two-day delivery) are designated.
  15. 29 C.F.R. § 4000.41 — What are these computation-of-time rules about?
    PBGCRegulationsJan 22, 2018
    …r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable computation-of-time rules under those other requirements. (Subpart A tells you what filing methods you may use for filings with us. Subpart B tells y…
  16. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997related by meaning
    ederal income tax. See sec. 6662(b)(2). As relevant herein, section 6662(a) imposes an accuracy-related penalty equal to 20 percent of an underpayment that is due to a substantial understatement of income tax. In the case of a corporation, a substantial understatement exists if its income tax was understated by the gre…
  17. Treas. Reg. § 301.6652-1(a)(1)(iii) — Failure to file certain information returns.
    IRCRegulationsDec 19, 2016related by meaning
    (a)(1)(iii) (iii) Section 6049(a)(1), relating to information returns with respect to payments of interest aggregating $10 or more in a calendar year, in effect with respect to payments made after December 31, 1962, and the regulations under such section, within the time prescribed for filing such statement (determined…
  18. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    … a result, DB Beneficiaries will not be included in calculations discussing “beneficiaries”. See 29 USC 1025 for more information. 3  Bureau of Labor Statistics, Job Opening and Labor Turnover. Table A, Total Private. February 2025. Most recent release can be found here: https://www.bls.gov/​news.release/​pdf/​jolts.pd…
  19. 119 T.C. No. 6 — Robert Ancira v. Commissioner
    IRCCourt RulingsSep 24, 2002related by meaning
    titioner is not liable for the sec. 6662 penalty. 3 S.K. apparently stands for Smoothie King, which we gather was the trade name of a product. OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Carleton D. Powell pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. 1 The Court agrees with and…